H. David Rosenbloom is a member in Caplin & Drysdale's Washington, DC office. He rejoined the firm in 1981 after serving as International Tax Counsel and Director of the Office of International Tax Affairs in the US Treasury Department from 1977 to 1981.
Services
Mr. Rosenbloom's major areas of practice include international tax planning and controversies, including transfer pricing and advance pricing agreements, the foreign tax credit and subpart F, tax treaty issues and competent authority proceedings, financial products and financial institutions, taxation of all forms of inbound investment, and individual tax compliance in a cross-border context.
Highlights
Mr. Rosenbloom has served as a Tax Policy Advisor for the US Treasury, the OECD, US AID, the International Monetary Fund, and the World Bank in Eastern Europe and the Baltic countries, the former Soviet Union, Senegal, Malawi, and South Africa. He has consulted with and advised foreign governments and international organizations on international tax matters, and served as an expert witness in international tax disputes in the United States, Canada, and New Zealand.
He has also written extensively on international and comparative tax topics. His most recent writings discuss the Foreign Account Tax Compliance Act, foreign tax credit generator transactions, and the saving clause in the U.S. tax treaties.
Professional Activities
- James S. Eustice Visiting Professor of Taxation and the Director of the International Tax Program at New York University School of Law
- Lecturer on international taxation at Harvard, Stanford, the University of Pennsylvania, and Columbia Law schools, and at universities in Sydney, Vienna, Melbourne, Milan, Bergamo, Bologna, Mexico City, Mainz and Heidelberg, and Rio de Janeiro
- Instructed at the University of Pretoria, the Universita del Piemonte Orientale in Italy, the Max Planck Institut in Munich, Seoul National University, Leiden University, the Public Finance Training Center in Taipei, and the OECD Multilateral Training Centres for Tax Offices from CIS and Eastern European Countries in Vienna, Ankara, and Budapest
Awards & Honors
- Recognized as a top lawyer in Chambers Global (2009-2012): 2012 – Band 1 in International Tax in the US; and Chambers USA (2008-2013): 2013 – Band 1 in Tax - District of Columbia, Band 2 in Tax Controversy - Nationwide
- Ranked as a leading lawyer in the 2010-2012 editions of The Legal 500 in International Tax
- Listed in The Best Lawyers in America in the specialty of Tax Law from 1989-2013
- Listed in Super Lawyers from 2007-2013
- Acknowledged by Legal Media Group in their Guide to the World's Leading Lawyers - Best of the Best USA 2009 and 2011-2012 and in their Guide to the World's Leading Tax Advisers; also recommended by PLC Which Lawyer? for international transfer pricing issues; AV rated by Martindale-Hubbell and listed in Washingtonian magazine's Top Lawyers in the 2009 and 2011-2012 editions
- AV rated by Martindale-Hubbell
Recent Media
- Chipmaker Altera, U.S. IRS Fight in Cross-Border Tax Case, Reuters (July 24, 2012)
- Eaton Expects $160 Million Tax Savings From Ireland Move, Bloomberg (May 21, 2012)
- Switzerland and the U.S.: What We Have Here is a Failure to Communicate, Tax Analysts (June 4, 2012)
- Law to Find Tax Evaders Denounced, The New York Times (December 26, 2011)
- Swiss Banks Near Deal to Disclose Customer Names to U.S., Financial Post (October 24, 2011)
- FATCA & Foreign Bank Accounts: Has the U.S. Overreacted?, Tax Analysts (May 31, 2011)
- Obama's Proposal to Simplify Tax Code Complicated by a Mix of Tax Breaks, Bloomberg (January 27, 2011)
- Potential Fallout from WikiLeaks Obtaining Swiss Bank Data, Marketplace (January 17, 2011)